P6 - Att P SUSQ - APP P-2 - SUSQ - Trench - v1

TRENCHLESS CROSSING ANALYSIS
Transcontinental Gas Pipe Line Company, LLC
ATLANTIC SUNRISE PROJECT
Central Penn Line

Susquehanna County, Pennsylvania
NOVEMBER 2016
TABLE OF CONTENTS
1.0 INTRODUCTION ......................................................................................................................................... 1

1.1 PROJECT BACKGROUND ............................................................................................................................... 2
1.2 PROJECT DESIGN AND CONSTRUCTION PRACTICES EMPLOYED ................................................................... 3
2.0 TYPICAL CONSTRUCTION METHODS ................................................................................................ 4
2.1 WATERWAY CROSSING PROCEDURES .......................................................................................................... 4
2.1.1 Dam-and-Pump Crossing ....................................................................................................................... 4
2.1.2 Flume Crossing ...................................................................................................................................... 5
2.1.3 Wet Open-Cut Crossing Method............................................................................................................. 5
2.1.4 Duration of Construction ....................................................................................................................... 6
2.2 WETLAND CROSSING PROCEDURES ............................................................................................................. 6
2.2.1 Standard Pipeline Construction (Non-Saturated Wetlands)................................................................... 7
2.2.2 Conventional Wetland Construction (Saturated) ................................................................................... 7
2.2.3 Push-Pull Technique .............................................................................................................................. 7
3.0 TRENCHLESS CONSTRUCTION – CONVENTIONAL BORE ........................................................... 8
3.1 CONVENTIONAL BORE TECHNIQUE.............................................................................................................. 8
3.2 CONVENTIONAL BORE RISK FACTORS ......................................................................................................... 8
3.2.1 Site Constraints and Topographic Considerations ................................................................................. 8
3.2.2 Mixed-Face Condition ............................................................................................................................ 9
3.2.3 Obstructions ........................................................................................................................................... 9
3.2.4 Soil Conditions ....................................................................................................................................... 9
3.2.5 Entry and Exit Pits ................................................................................................................................ 10
3.2.6 Drill Hole Failure ................................................................................................................................ 11
4.0 TRENCHLESS CONSTRUCTION – HORIZONTAL DIRECTIONAL DRILL (HDD) .................... 11
4.1 HDD TECHNIQUE ...................................................................................................................................... 11
4.2 HDD RISK FACTORS .................................................................................................................................. 12
4.2.1 Site Constraints and Topographic Considerations ...............................................................................12
4.2.2 Elevation Differential and Dry Hole ..................................................................................................... 14
4.2.3 Hole Stability ........................................................................................................................................ 14
4.2.4 Obstructions ......................................................................................................................................... 15
4.2.5 Pilot Hole Steering ............................................................................................................................... 15
4.2.6 Drilling Fluid Loss, Hydraulic Fracture and Inadvertent Returns........................................................ 16
4.2.7 Poor Cuttings Removal ......................................................................................................................... 16
4.2.8 Hole Obstructions and Flushing ........................................................................................................... 17
4.2.9 Downhole Tooling Failure / Loss.......................................................................................................... 17
4.2.10 HDD Time of Installation 17
4.3 HDD ENVIRONMENTAL FACTORS ............................................................................................................. 17
5.0 SUMMARY OF CONSTRUCTION METHODS FOR ATLANTIC SUNRISE ................................... 19
6.0 RESOURCE CROSSING EVALUATION METHODOLOGY ............................................................. 20
6.1 OVERVIEW ................................................................................................................................................. 20
6.2 CONVENTIONAL BORE ASSESSMENT FOR WATERWAYS ............................................................................ 20
6.3 HDD ASSESSMENT FOR WETLANDS AND WATERWAYS ............................................................................ 24
6.4 EQUIPMENT AND SKILLED LABOR ASSESSMENT ........................................................................................ 27
ATLANTIC SUNRISE PROJECT ii Trenchless Crossing Analysis

7.0 RESULTS OF TRENCHLESS CROSSING ANALYSIS – SUSQUEHANNA COUNTY ................... 27
7.1 CONVENTIONAL BORES ............................................................................................................................. 27
7.2 HDDS ........................................................................................................................................................ 27
7.3 GEOLOGICAL ASSESSMENTS ...................................................................................................................... 27
8.0 RESULTS OF EQUIPMENT / SKILLED LABOR ASSESSMENT...................................................... 27
LIST OF FIGURES
Figure 1: Bore Pit Depth - Determining Factors ......................................................................................... 22
LIST OF TABLES
Table 1: Summary of Construction Methods for the Atlantic Sunrise Project ........................................... 19
Table 2: Waterways Assessed for Conventional Bores .............................................................................. 28
Table 3: Waterways Assessed for HDD ..................................................................................................... 29
Table 4: Wetlands Assessed for HDD ........................................................................................................ 30
LIST OF APPENDICES
Appendix A Flow Chart of Trenchless Crossing Analysis
ATLANTIC SUNRISE PROJECT iii Trenchless Crossing Analysis

1.0 INTRODUCTION
This Trenchless Crossing Analysis (Analysis) evaluates the potential use of trenchless construction methods
to minimize impacts to wetlands and waterways associated with the proposed Atlantic Sunrise Project
(Project). In August 2015, Transcontinental Gas Pipeline Company (Transco) submitted eight Joint Permit
Applications for a Water Obstruction and Encroachment Permit to the Pennsylvania Department of
Environmental Protection (PADEP) under Chapter 105 of Title 25 of the Pennsylvania Code. These
applications covered each of the eight counties crossed by the Central Penn Line (CPL) pipeline alignment.
Subsequent to issuance of Notices of Complete Application, PADEP issued technical deficiency letters on
July 29, 2016 requesting additional information on the eight applications.
One of the technical deficiency requests that was common across all counties was to provide additional
documentation of trenchless alternatives for crossing wetlands and waterways. Specifically, the deficiency
stated ‘It appears that several waters of the Commonwealth could be crossed using trenchless installation
methods. Provide a revised alternatives analysis that incorporates a discussion of alternative crossing
techniques (conventional bore, HDD, micro-tunneling, etc.) addressing each resource crossing individually
and explaining why trenchless installation methods are not appropriate’. Since the term ‘waters of the
Commonwealth’ extends to both wetlands and waterways, Transco has incorporated both types of resources
in its analysis.
In its technical deficiency regarding the use of trenchless crossing technology, PADEP provides two
regulatory citations:
 25 PA. Code §§ 105.13(e)(1)(viii) – Alternatives analysis. A detailed analysis of alternatives to

the proposed action, including alternative locations, routings or designs to avoid or minimize
adverse environmental impacts.
 25 PA. Code §§ 105.18(a) – Exceptional value wetlands. Except as provided for in subsection (c),
the Department will not grant a permit under this chapter for a dam, water obstruction or
encroachment located in, along, across or projecting into an exceptional value wetland, or otherwise
affecting an exceptional value wetland, unless the applicant affirmatively demonstrates in writing
and the Department issues a written finding that the following requirements are met:
(1) The dam, water obstruction or encroachment will not have an adverse impact on the
wetland, as determined in accordance with § § 105.14(b) and 105.15 (relating to review of
applications; and environmental assessment).
(2) The project is water-dependent. A project is water-dependent when the project requires
access or proximity to or siting within the wetland to fulfill the basic purposes of the
project.
(3) There is no practicable alternative to the proposed project that would not involve a wetland
or that would have less effect on the wetland, and not have other significant adverse effects
on the environment. An alternative is practicable if it is available and capable of being
carried out after taking into consideration construction cost, existing technology and
logistics. An area not presently owned by the applicant which could reasonably be
obtained, utilized, expanded or managed to fulfill the basic purpose of the project shall be
considered as a practicable alternative.
ATLANTIC SUNRISE PROJECT 1 Trenchless Crossing Analysis

As previously presented within Attachment P of the Joint Permit Application, the objective of Transco’s
alternatives analysis is to develop proposed pipeline routes that will be constructible, accomplish the
Project’s purpose, and will avoid or minimize potential adverse environmental impacts and landowner
concerns. This analysis was developed to be consistent with the Federal Energy Regulatory Commission’s
regulatory requirements as set forth in 18 Code of Federal Regulations 380.15 and 25 PA. Code §
105.13(e)(viii).
An overview of routing considerations is provided in Section 1.2, and alternative routes considered have
been presented in Resource Report 10, submitted as a part of Transco’s application to the Federal Energy
Regulatory Commission (FERC) for a Certificate of Public Convenience and Necessity. Furthermore,
Transco will provide field routing notes within the updated application in response to PADEP’s technical
deficiency #13 issued for Susquehanna County. Although this report focuses on construction techniques
as a means of impact avoidance and minimization, Transco has a taken a holistic approach to minimize
impacts using a combination of route selection, construction techniques, and best management practices.
To provide a complete response to this technical deficiency request, Transco has evaluated the potential use
of trenchless installation techniques based on specific criteria for both wetlands and waterways. This
analysis provides the following: a general description of the Project; an overview of and limitations
associated with the various construction techniques used to install the pipeline across or under wetlands and
waterways; a description of the systematic methodology used to determine feasibility of trenchless
installation for both types of resources; the results of the analysis on an individual resource basis; an
assessment of skilled labor and equipment availability to complete trenchless crossings and a discussion of
the how this analysis has or has not modified the Project-related impacts to wetlands and waterways.
1.1 Project Background
The Project is a proposed expansion of the existing Transco natural gas transmission system. This proposed
expansion will enable Transco to provide 1.7 million dekatherms per day of incremental firm transportation
of natural gas from the Marcellus Shale production areas in northern Pennsylvania to its existing market
areas, extending as far south as the Station 85 Pooling Point in Choctaw County, Alabama.
The Project includes modifications to the existing Transco Mainline system consisting of the following
primary components:
 58.6 miles of new 30-inch-diameter and 127.3 miles of 42-inch-diameter greenfield pipeline in
Pennsylvania (Central Penn Line);
 2.5 miles of new 36-inch-diameter and 8.5 miles of 42-inch-diameter pipeline loops in
Pennsylvania;
 Two new compressor stations in Pennsylvania;
 Additional ancillary facilities, such as mainline valves (MLVs), cathodic protection,
communication facilities, and internal inspection device (e.g., pig) launchers and receivers in
Pennsylvania;
 Two new meter stations and three new regulator stations with interconnecting piping in
Pennsylvania;
 Additional compression and related modifications to two existing compressor stations in
Pennsylvania; and

 Modifications to the existing Transco Mainline system in other states to enable new north-to-south
capabilities (bi-directional flow) to transport this new source of natural gas to existing markets.
1.2 Project Design and Construction Practices Employed
Transco has sought to avoid or minimize impacts to sensitive resources, to the extent practicable, by
utilizing design and construction practices as detailed below.
When identifying routing options, Transco attempted to co-locate the pipeline with existing utility corridors
and Right-of-Ways (ROWs) while considering impacts on other environmental factors. The use of co-
location as a principal design element is consistent with the FERC guidelines, which stress the corridor
concept, and complements the existing land use characteristics in the Project area. Siting pipeline facilities
along existing corridors reduces the need to establish new corridors in previously undisturbed areas, which
reduces the amount of fragmentation of interior forest and minimizes the number of affected landowners.
Transco defines co-location as siting a pipeline ROW that:
 Lies within an existing ROW or easement; or

 Abuts an existing ROW or easement.
The following routing considerations influenced the development of the proposed routes:
 Identifying crossing locations of the Susquehanna River where, based on terrain, horizontal
directional drilling (HDD) appeared to be technically feasible;
 Crossing areas of significant topographic relief where technically feasible;
 Avoiding state lands, including state parks, state forests, and state game lands to the extent
practicable; and
 Avoiding densely populated areas to the extent practicable.
After taking the above into consideration, Transco narrowed its analysis to 600-foot-wide study corridors
for the CPL North and CPL South pipeline routes, which were determined based on desktop data and aerial
reconnaissance (helicopter overflights). Once this initial routing process was complete, Transco then began
field routing efforts within these study corridors. These field efforts began in May 2014 and have been
completed to the extent that landowner approval has been granted.
Transco used various data sources to identify and evaluate pipeline route alternatives, including:
observations made during routing surveys and field reconnaissance; Google Earth™; geographic
information system databases from county, state, and federal sources; recently produced aerial
photography; U.S. Geological Survey (USGS) topographic maps; National Wetland Inventory maps; and
remote-sensing data. The factors used to select the proposed routes over the alternative routes focused on
the FERC scoping information, landowner concerns, minimizing the number of affected landowners,
minimizing adverse environmental impacts, ensuring constructability, and promoting safety.
Since field surveys began in the spring of 2014, Transco has refined the alignment of the Central Penn Line
to avoid or minimize impacts to sensitive resources to the extent practicable. Since the initiation of the
FERC pre-filing process, Transco has adopted approximately 190 reroutes and 91 minor deviations,
resulting in a modification of approximately 150.25 miles (84.1 percent) of the pre-surveyed pipeline route.

The construction and restoration procedures described in the Project Environmental Construction Plans
(ECPs) are anticipated to fully restore and stabilize temporarily disturbed workspace locations, and promote
natural revegetation of the ROW. During operation of the Project, Transco will be limiting the permanently
maintained corridor to 50 feet in width centered over the pipeline in uplands. Areas where forested and
scrub-shrub wetlands currently exist will reduce the permanently maintained portion of the ROW to 10 feet
in width centered over the pipeline. Select removal of trees within 15 feet of the pipeline with roots that
could compromise the integrity of the pipeline coating will also be conducted within forested wetlands. To
minimize potential Project-related impacts on sensitive or high quality waterways supporting trout fisheries,
Transco is planning construction activities to occur within the in-stream work windows recommended by
the Pennsylvania Fish and Boat Commission (PFBC).
2.0 TYPICAL CONSTRUCTION METHODS

2.1 Waterway Crossing Procedures
Various methods will be used to install the pipeline across waterways, depending on waterway
classifications and flow conditions at the time of crossing. Consistent with the FERC Procedures,
waterways are classified as “minor,” “intermediate,” or “major,” as follows:
 Minor waterway includes all waterways less than or equal to 10 feet wide at the water’s edge at the
time of crossing;
 Intermediate waterway includes all waterways greater than 10 feet wide but less than or equal to
100 feet wide at the water’s edge at the time of crossing; and
 Major waterway includes all waterways greater than 100 feet wide at the water’s edge at the time
of crossing.
Transco is considering the use of each waterway crossing method described below. Transco anticipates
that most waterway crossings will be completed using one of the following methods and typically
completed within 24 to 48 hours.
2.1.1 Dam-and-Pump Crossing
The dam-and-pump crossing method consists of diversion structures used to temporarily dam the waterway,
which can consist of one or more of the following: concrete jersey barriers, water bladders, port-a-dams,
steel plates, and/or sand bags. The selection of the dam type or material depends on the stream or waterway
depth, flow velocity, channel width, and flow type.
This method for crossing streams and waterways temporarily diverts stream flow around construction area
activities while maintaining downstream flow at all times. Damming structures will be installed upstream
and downstream of the proposed trench. Pumps and hoses will be used to convey flow around the in-stream
work area, discharging the water downstream of the construction site and creating a dry work area. Multiple
discharge pumps may be required to keep the area dry and maintain adequate flow to avoid flooding of the
waterway upstream. The trench then will be excavated, and the pipe will be installed in the dry ditch.
While the upstream and downstream dams are being installed, the pumps will be used to divert water around
the pipeline crossing and associated workspaces. The water will be discharged to the downstream area
through an energy dissipating (or similar) device to prevent erosion and scouring and minimize turbidity.
Once the pipe is installed, the trench will be backfilled to preconstruction contours, and stream banks will
be restored prior to restoring water flow.

The following additional stipulations will apply to all dam-and-pump waterway crossings:
 Sufficient pumps, including on-site backup pumps, will be used to maintain downstream flows;
 Dams will be constructed with materials that prevent sediment and other pollutants from entering
the waterway;
 Pump intakes will be screened to minimize entrainment of fish; and
 Dams and pumps will be continuously monitored to ensure proper operation throughout the
waterway crossing.
2.1.2 Flume Crossing
Flume pipe(s) will be installed over the trench prior to trenching (or during trenching if a rain event creates
flow in a dry stream channel). Flume pipes will remain in place and be maintained until restoration of the
waterway is complete, and downstream flow will be maintained at all times. The size and number of flumes
will be determined prior to installation based on engineering calculations and will be adequate to handle
the maximum anticipated flow during the time of the crossing. Excavation equipment located on the stream
banks will work around the flume pipe during excavation. The pipe will be threaded under the flume pipe,
and the ditch will be backfilled while flows are maintained through the flume pipe(s) and downstream.
Flume pipes will be permanently removed as part of restoration.
The following additional stipulations will apply to all flume waterway crossings:
 Sand bags or sand bag with plastic sheeting diversion structures or equivalent will be used to
develop an effective seal and to divert stream flow through the flume pipe;
 Flume pipes will be properly aligned to prevent bank erosion and stream bed scour;
 Flume pipes will not be removed during trenching, pipe laying, or initial stream bed restoration
activities; and
 All flume pipes and dams that are not part of the equipment bridge will be removed as soon as final
cleanup of the stream bed and bank is complete.
2.1.3 Wet Open-Cut Crossing Method
The wet open-cut construction method involves the excavation of the pipeline trench across the waterway,
installation of a prefabricated pipeline segment, and backfilling of the trench with excavated material.
Depending on the width of the crossing and the reach of the excavating equipment, excavation and
backfilling of the trench will generally be accomplished using backhoes or other excavation equipment
operating from one or both banks of the waterway. Excavated material from the trench will be placed on
the bank above the ordinary high water mark for use as backfill. The pipe segment can be weighted, as
necessary, to provide negative buoyancy and placed below scour depth. Typical backfill cover
requirements will be met, contours will be restored within the waterway, and the banks will be stabilized
via seeding and/or the installation of erosion control matting or riprap, per applicable regulatory approvals.
The following additional stipulations will apply to wet open-cut stream crossings:
 In-stream construction activities (including trenching, pipe installation, backfill, and streambed
restoration) will be completed within 24 hours when crossing minor waterways and within 48 hours

when crossing intermediate waterways, unless site-specific conditions make completion with these
time frames infeasible;
 Operation of equipment in the waterway will be limited to that needed to construct the crossing;
and
 Material excavated from the trench will be stockpiled in the construction ROW at least 10 feet from
the water’s edge or in additional extra work areas.
2.1.4 Duration of Construction
Open-cut crossings of waterways less than 100 feet in width are typically completed within 24 to 48 hours.
While restoration activities may occur over a longer period of time, the physical process of installing the
pipeline across the stream is done in an expedited manner to minimize in-stream activity and associated
impacts. With respect to timing of activities, the open-cut crossing method is the fastest of any of the crossing
methods described herein.
2.2 Wetland Crossing Procedures
The width of the construction ROW will be limited to 75 feet in wetlands, except where ATWS is requested
for site-specific conditions. Operation of construction equipment through wetlands will be limited to only
that necessary for each stage of pipeline installation (e.g., clearing, trenching). Topsoil segregation
techniques will be used in unsaturated wetlands to preserve the seed bank and allow for successful
restoration. Wetland crossing methods will be determined based on site-specific conditions. Transco will
use one of the following methods to install the pipeline within wetlands (please note that all methods will
not necessarily be used in every county crossed):
 Standard Pipeline Construction (non-saturated wetland),

 Conventional Wetland Construction (saturated wetland), and/or
 Push-Pull Technique (inundated wetland).
Transco will use the standard pipeline construction method in wetlands where soils are non-saturated and
able to support construction equipment at the time of crossing. The conventional wetland construction
method will be used for crossing wetlands with saturated soils or soils unable to support construction
equipment without considerable soil disturbance. Inundated wetlands may require installation via the push-
pull method, in which the pipe will be floated along the open trench. The welded pipe will be pushed along
the water-filled trench until it is in place. Once in place within the trench, the floats attached to the pipe
will be removed and the pipe will be allowed to sink into place.
Transco will construct the Project through wetlands in accordance with its Project-specific ECP as well as
the FERC Wetland and Waterbody Construction and Mitigation Procedures and applicable federal and state
environmental permit conditions. Transco will implement minimization measures within wetlands
including workspace reduction and segregation of topsoil within the trenchline. Additionally, Transco will
not remove stumps within wetlands with the exception of those directly within the trenchline and where
stumps may present a safety concern for equipment and/or construction personnel. Wetlands will be
restored subsequent to completion of construction, and there is no permanent wetland loss associated with
the Project.

2.2.1 Standard Pipeline Construction (Non-Saturated Wetlands)
The Standard Pipeline Construction method will be utilized in wetlands where soils are non-saturated and
able to support construction equipment at the time of crossing. This method requires segregation of topsoil
from subsoil along the trenchline. Where present, a maximum of 12 inches of topsoil will be segregated
from the area disturbed by trenching, except where soils are frozen, standing water is present or soils are
saturated, or where shallow depth to bedrock exists. These exceptions will be identified in the field with
the Environmental or Agricultural Inspector. Topsoil segregation is followed by trench excavation, pipe
laying, backfilling, and grade restoration. Immediately after backfilling is complete, the segregated topsoil
is restored to its original location. Erosion control measures, including site-specific contouring, silt fence,
hay-bale barriers, permanent slope breakers, mulching, and reseeding or sodding with soil-holding
vegetation, will be implemented. Contouring will be accomplished using acceptable excess soils from
construction. Where this method is to be implemented for construction, the environmental inspector will
measure the pre- and post-construction soil density using a penetrometer to determine if the soil has been
inadvertently compacted during construction or access. If the soils are found to be compacted, de-
compaction of the soil will be conducted using a harrow, paraplow, paratill, or other equipment. Deep
subsoil shattering, if necessary, will be performed with a subsoiler tool having angled legs.
2.2.2 Conventional Wetland Construction (Saturated)
The Conventional Wetland Construction method will be used for crossing wetlands with saturated soils or
soils unable to support construction equipment without considerable soil disturbance. Prior to crossing and
movement of construction equipment through these wetlands, the ROW will be stabilized using equipment
mats to allow for a stable, safe working condition. Unless soils are inundated or saturated, a maximum of
12 inches of topsoil will be segregated from the area disturbed by trenching. Trench spoil will be stockpiled
temporarily in a ridge along the pipeline trench. Gaps in the spoil pile will be left at appropriate intervals
to provide for natural circulation or drainage of water.
While the trench is being dug, the pipeline will be assembled in a staging area located in an upland area.
The pipe will then be moved from the assembly area to the ROW. After the pipeline is lowered into the
trench, wide track bulldozers or backhoes supported on equipment mats will be used for backfill, final
cleanup, and grading. This method will minimize the amount of equipment and travel in wetland areas.
2.2.3 Push-Pull Technique
Construction in saturated/inundated wetland areas may involve the Push-Pull Technique. The Push-Pull
Technique is used in large wetland areas (>300 feet crossing length) where sufficient water is present for
floating the pipeline in the trench, and grade elevation over the length of the push-pull area will not require
damming to maintain adequate water levels for flotation of the pipe. If dry conditions prevail, the push-
pull method will not be viable. This method involves pushing the prefabricated pipe from the edge of the
wetland or pulling the pipe with a winch from the opposite bank of the wetland into the trench. For
implementation of this technique, initial clearing within the wetland will be minimized. The width of the
ROW cleared will be limited to only that necessary to install the pipeline. Grading in inundated wetlands
will be held to a minimum and generally will not be necessary, due to the typically level topography and
the absence of rock outcrops in such areas.
Equipment mats may be placed over existing vegetation where grading is not required. Trees and brush
will be cut at ground level by hand, with low ground pressure equipment, or with equipment supported by
equipment mats. Transco will not use dirt, rock, pulled tree stumps, or brush rip-rap to stabilize the travel
lane, and sediment barriers will be installed prior to grading, as needed, to protect adjacent wetland areas.

The trench will be excavated using amphibious excavators (pontoon mounted backhoes) or tracked
backhoes (supported by fabricated equipment mats or floats). The excavated material will be stored
adjacent to the trench, if possible. If storage of excavated material next to the trench is not possible, the
material will be stored temporarily in one of the following locations: (1) in upland areas of the ROW as
near to the trench as possible, (2) in construction vehicles, or (3) at an approved off-site staging location
until needed for backfilling. The pipe will be stored and joined at staging areas (push and pull sites) located
outside of the wetland. Floats may be attached temporarily to give the pipe positive buoyancy. After
floating the pipe into place, these floats will be cut and the negatively buoyant pipe will settle to the bottom
of the ditch. This operation will be repeated, with pipe sections fabricated, welded together, and pushed
into place until the wetland crossing is complete. The excavated material then will be placed over the pipe
to backfill the trench.
3.0 TRENCHLESS CONSTRUCTION – CONVENTIONAL BORE

3.1 Conventional Bore Technique
Conventional boring consists of creating a shaft/tunnel for a pipe to be installed to minimize surface
disturbance. This is accomplished by first excavating a bore pit and a receiving pit. The bore pit is
excavated to a depth that allows the pipeline to maintain a safe clearance underneath the resource being
avoided, and is graded such that the bore will follow the proposed angle of the pipe. A boring machine is
then lowered to the bottom of the bore pit to tunnel using a cutting head mounted on an auger. The auger
rotates through a bore tube, both of which are pushed forward as the hole is cut. The pipeline is then
installed through the bored hole and welded to the adjacent pipeline. The typical workspace configurations
required for boring operations consists of approximately two, 50 foot by 100 foot staging areas for boring
machine setup, cuttings/return settlement and storage pits, pipe storage, entrance and exit pit spoil storage
and construction equipment necessary to support the operation, in addition to nominal workspace required
for conventional lay. Topography and subsurface conditions can greatly influence the workspace associated
with a conventional bore. Additionally, a travel lane and temporary bridge will be necessary during
construction to facilitate movement of equipment for construction activities. The duration of construction
for conventional bore crossings of wetlands and waterbodies typically ranges from 3 to more than 4 weeks,
depending on the pipe diameter, crossing length, topography, soil conditions, and the need for blasting in
areas of shallow bedrock.
ROW corridors will be maintained as described in Attachment J of the application submitted in March
2015.
3.2 Conventional Bore Risk Factors
It is important to predicate any discussion of trenchless construction risk with the understanding that
although risk factors may be identified and presented individually, in the context of overall construction
risk, the factors should be considered interrelated and in varying degrees, reactive with and upon one
another. Thus, the risks should be evaluated as a whole.
3.2.1 Site Constraints and Topographic Considerations
The existing ground topography and site features may require significant entry and exit pit excavation depths
to obtain the desired depth of cover for the conceptual conventional bore beneath the deepest part of the
waterbodies. Soil borings would be required to fully evaluate subsurface conditions, necessitating tree
clearing and grading of steep slopes for the drilling equipment to access the boring locations, which would

need to be as near to the waterbody as possible. Other site and topographic constraints are discussed in the
paragraphs below.
3.2.2 Mixed-Face Condition
A mixed-face condition occurs when the cutting tool encounters both soil and rock formations in the tunnel
face. This can result in difficulties in boring including, but not limited to, deflection of the conventional
bore tooling and pipe, seizing of the auger as it encounters boulders along the soil-rock interface, and over-
mining of soil which can lead to soil raveling into the bore pipe.
Soil borings would be needed to fully evaluate the subsurface soil conditions, potentially necessitating
tree clearing and grading of steep slopes for drilling rig access. The depth of cover may need to be
increased to contain the conventional bore within a homogeneous soil strata, resulting in deeper entry and
exit pits and increased workspace sizes.
3.2.3 Obstructions
Conventional auger boring techniques will be at a risk of encountering obstacles (cobble and boulders) that
would potentially stop the forward movement of the bore pipe casing. Generally, an auger bore can ingest
a cobble or boulder up to one-third the diameter of the casing. For a 30-inch-diameter sacrificial bore
pipe this would be about a 10-inch cobble, while a 42-inch-diameter bore pipe could ingest a 14-inch
diameter boulder. Cobble and boulder size clasts in excess of 10 or 14 inches in diameter could be
encountered and may not be of ingestible size if fully within the tunnel zone, and/or potentially too hard to
be broken down to an ingestible size if partially within the tunnel zone, resulting in stopping the forward
movement of the sacrificial bore pipe. These features may not be present in soil boring data and therefore
present a high risk during construction.
If an obstruction is present that stops the forward movement of the sacrificial bore pipe and/or the augers,
there are limited remedies to remove the obstruction. Since man-entry is not an option, the only recourse
would be to either use a pipe ram to try to advance the sacrificial bore pipe, to use a down-the-hole hammer
to break up the obstruction, or to access the face of the auger bore from the ground surface to remove the
obstruction. Both pipe ram and down-the-hole hammer options are risky with no guarantee of success.
The last resort would be to use a pipe ram in reverse to pull the sacrificial bore pipe out, and try crossing at
a different location or elevation where the geology may be more favorable. If forward movement of the
sacrificial bore pipe is halted, and attempting a crossing at a different adjacent location is the most feasible
option remaining, new or expanded entry and exit pit excavations may be required as well as additional
dewatering as needed, and potentially the expansion of additional temporary workspace.
3.2.4 Soil Conditions
If soils with lower clay contents are encountered during construction, these soils may present the challenge
of flowing soils with all of the above-referenced potential risks. If flowing soils are encountered the entire
tunnel zone would likely need to be dewatered and the waterbody diverted to accomplish the auger bore.
Dewatering may generate large volumes of water that will require handling and disposal. Such dewatering
measures would likely lower the groundwater table as well. The disturbance associated with constructing
dewatering wells across the waterbody channel may negate the desired benefits of a trenchless method of
construction.

3.2.5 Entry and Exit Pits
The soils near the boring and the depths of the bore pits will present challenges with respect to shoring for
entry and exit pit construction. Ground water is anticipated to be present during construction. These
excavations may require continuous (entry pit) and temporary (exit pit) dewatering, which could generate
large volumes of water that will require handling and disposal and could lower the groundwater table
within the waterbody. Shoring will be necessary for protection of workers and equipment. Sheetpile
shoring is frequently used for conventional bore construction. However, the density of the soils at depth,
the presence of cobbles and boulders, the unknown depth of bedrock, and the required depths for installation
may limit the ability to drive the sheet piles into place. Blasting may be needed to install the pits if
consolidated rock is encountered.
Worker safety is a top priority. Per company Job Safety Analysis (JSA) policy and in accordance
with Occupational Safety and Health Administration (OSHA) regulations, Transco has identified
multiple safety hazards associated with the conventional bore crossing method. Specifically, the work
required to be conducted within the entry and exit pits (i.e., confined space) poses significant risks due to the
pit depth (20-feet and greater) and the potential for unanticipated and sudden flooding (below water table
for majority of pit depth).
Conventional bores are typically used to cross features that have a higher elevation than the adjacent
landscape, where entry and exit bore pits would be located. Bore pit depths associated with such crossings
(often roadways) do not pose a significant hazard. However the crossing of streams and wetlands, where the
feature is below the elevation of the start and end of a bore, adds many additional challenges and hazards. The
largest hazard is the extra excavation/depth required to develop the necessary depth of cover between the
pipe and feature. While a 10-foot to 15-foot bore pit depth may be typical for a road crossing, steep terrain
may put the necessary depth of a wetland or waterbody pit over 20-foot in depth. This requires additional
safeguards (such as trench boxes, dedicated safety teams,) etc. As the pits become deeper, more workspace
is required to store the excavated pit material and to bench/slope the work area around the pit for safety and
construction equipment access. As many waterbodies are in forested areas, these extra workspaces will have
direct impacts on forested areas adjacent to the pits. Wetlands have a tendency to be located adjacent to
streams as well. It may be necessary to store spoils on top of matting or excavate within the wetlands to install
the bore pits successfully.
There is also a risk of the bore pipe becoming a conduit for the groundwater and then subsequently flooding
the entry pit suddenly, thereby creating a hazard for the operators. Transco is committed to protecting the
safety of both Company and Contractor personnel by minimizing exposure to hazards. Through execution
of the Company hazard assessment policy, the basic hazards associated with work conducted in a confined
space (e.g., ease of ingress/egress from the pits, air quality, and excavation wall stability) can be mitigated,
though excessive depth will require an extensive cave-in protection system to be designed by a
professional engineer. While the cave-in hazard may be mitigated, the extended depths cannot be avoided.
This depth substantially increases the risks of all associated hazards (e.g., worker injury resulting from
suspended loads) and could significantly hamper evacuation in the event of an emergency. In addition, the
hazards associated with unforeseen/unknown circumstances, specifically the volume of water that could
enter the pits via the bore pipe and the speed with which it could enter, cannot be avoided or mitigated with
absolute certainty.
Transco has evaluated the hazards associated with both the conventional bore and open-cut crossing
methods. While open-cut crossing methods also present challenges, including work within excavations,
the associated hazards can be better mitigated. For example, the depth of bell holes used to tie-in the
waterbody pipe segment would be approximately 8-feet, which can be mitigated through excavation

(benching/sloping) and shoring techniques. Open-cut crossing methods eliminate both worker exposure to
the deep pits and the potential for flooding via the bore pipe.
3.2.6 Drill Hole Failure
Drill hole failure (collapse of the drill hole) during drilling operations is one of the greatest risks to the
successful completion of a conventional bore. If flowing soils are encountered, the bore pipe can become a
conduit and suddenly flood the entry pit without warning. The streambed could collapse through the bore
pipe requiring extensive restoration as well as draining the stream.
4.0 TRENCHLESS CONSTRUCTION – HORIZONTAL DIRECTIONAL

DRILL (HDD)
4.1 HDD Technique
HDD is a trenchless method of installing pipelines in areas where neither traditional open cut excavations
nor conventional bores are feasible due to sensitive resource areas or logistical reasons. With an HDD,
open cut trenching and equipment disturbance may not be necessary near the sensitive resource, and as a
result, environmental impacts on sensitive resource areas are minimized. However, a greater amount of
equipment staging workspace is required for HDD than for the open cut crossing method, and typical
installation of an HDD segment will take several months.
In ideal conditions, a minimum workspace footprint of 200 feet wide by 250 feet long is typically required
at both the entry and exit points to support the drilling operation. The amount of workspace required can
increase significantly based on site specific conditions. The entry-side equipment and operations typically
will include the drilling rig and entry hole, control cab, drill string pipe storage, site office and tool storage
trailers, power generators, bentonite storage, bentonite slurry mixing equipment, slurry pump, cuttings
separation equipment, cuttings return/settlement pit, water trucks and water storage, and the heavy
construction equipment necessary to support the operation.
Exit-side equipment and operations typically will include the exit point and slurry containment pit, cuttings
return/settlement pit, cuttings separation and slurry reclamation equipment, drill string pipe storage, and the
heavy construction equipment necessary to support the operation. In addition to the footprint associate with
drilling operations, Additional Temporary Workspace (ATWS) will be required along the working side
ROW. ATWS in the form of false ROW may be required at HDD locations where the ROW changes
direction from the orientation of the drill. This false ROW provides a straight corridor for handling pipe
and prefabricating the pipeline into one continuous section in preparation for the pull-back. Because this
false ROW must be relatively straight to accommodate a long section of pipe before it is pulled through the
annulus, a significant area of ATWS would be required outside of the standard pipeline construction
workspace. Once assembled, the pipeline will be placed on pipe rollers so that it may be conveyed into the
drill hole during the pull-back operation.
Risks associated with a HDD crossing technique include:
 Potential inadvertent returns of fluids and tailings during HDD drilling operations;
 Potential drill hole collapse during construction or subsequent settlement of HDD locations
following installation;
 Pipeline inaccessibility for visual inspection and repairs;

 Pipeline denting and/or coating damage during pullback ;and
 Uneven cathodic protection on the pipeline.
Transco has developed a HDD Contingency Plan (Appendix 3 of the Environmental Construction Plan)
to establish procedures for addressing potential impacts associated with an inadvertent release of drilling
fluid through hydraulically-induced cracks. The plan identifies operational procedures and responsibilities
for the prevention, containment, and clean-up of drilling fluids in the event a release occurs to the ground
surface or within a waterway during HDD operations. Uneven cathodic protection across a pipeline
segment can occur due to the effects of geologic strata changes and difficulty in identifying interference
with cathodic protection due to external forces. Although Transco uses in-line inspection tools to identify
anomalies as part of its integrity management program, the depth of the HDD pipe does not allow potential
anomalies to be visually inspected and verified, and anomalies cannot be accessed for repair. Such
anomalies may include external coating defects, corrosion, stress corrosion cracking, and dents. Therefore,
the pipe utilized for HDD operations is generally a thicker-walled diameter pipe that is subject to x-ray
inspection following assembly, and is treated with fusion-boned epoxy coating and coated with abrasion-
resistant overlay prior to installation. These measures minimize the potential for damage or corrosion
occurring to the pipeline.
The length of land-based 30-inch HDDs are limited to approximately 7,000 feet in length for the highest
probability of success, while 42-inch HDDs are limited to approximately 6,000 feet in length. The longer
the length, the more forces are applied to the pipe and the larger potential for failures and additional pullback
area restraints.
4.2 HDD Risk Factors
It is important to predicate any discussion of trenchless construction risk with the understanding that
although risk factors may be identified and presented individually, in the context of overall construction
risk, the factors should be considered interrelated and in varying degrees, reactive with and upon one
another.
4.2.1 Site Constraints and Topographic Considerations
In an effort to reduce the risk of hole collapse, hole flushing and dry hole conditions, HDD’s are designed
with an entry and exit point at or near the same elevation. When a significant elevation difference between
the entry and exit point is unavoidable, a portion of the drilled hole will not be filled with drilling fluid. In
rock formations, this increases the risk of drill tool failure because the tools may not be adequately cooled
and lubricated through the dry section of the hole, despite drilling fluid being pumped during operations. In
soil formations, the risk of hole collapse is also elevated, which may lead to ground surface settlement along
the HDD alignment, damage to structures, inadvertent drilling fluid release to the surface, or a stuck pipe
during pullback operations.
Locating suitable areas for entry and exit sites can be challenging, especially in steep, hilly terrain. The
site needs to be as flat as possible, and any relief on the site in question will need additional space to grade
and stockpile soil, which would further increase impacts to the surrounding resources (i.e., trees, wetlands,
agricultural fields). In ideal conditions, a normal entry site can be as small as an acre, however this can
grow substantially dependent upon the terrain and other site conditions. The length separating the entry
and exit point is also a function of the pipe’s allowable bending radius, as well as the terrain and soil
conditions. This bending radius dictates the minimum horizontal length that an HDD can accommodate; it
will take a substantial horizontal distance to allow the pipe to travel underneath the sensitive resource and

curve back up to its typical depth of cover. Even if a feature is only a few feet wide, if an HDD is required,
it could take several thousand feet for the HDD to cross features in a steep valley. HDDs may also be
lengthened to avoid certain soil strata that are more susceptible to inadvertent returns.
Due to the radius of curvature required to install a large diameter pipeline using the HDD technique, the
pipe is usually installed at depths greater than 50-feet below the ground surface, which poses considerable
operational implications. If in-line inspection activities indicate that maintenance or repairs are needed for
a section of pipe that has been installed using the HDD technique, the pipeline’s installation depth would
render it inaccessible for repairs. In these cases, the section of pipe would have to be abandoned in-
place. There would be additional environmental impacts resulting from the need to install a second HDD
parallel and adjacent to the original HDD section, assuming adequate space is available for a replacement
HDD section to be installed. As an industry practice, for long-term operations and maintenance purposes,
an HDD is only utilized where no other construction method is deemed feasible and where adequate space
exists for a replacement pipeline in the event the HDD section must be replaced (e.g., at very large river
crossings).
To support an HDD, a minimum workspace of 200-feet wide by 250-feet long is typically required at the
entry and exit points. Additionally, a pullback stringing workspace of 50-feet in width by the length of the
crossing (1,300-feet to 6,000-feet or more in length) to place and weld pipe before it is pulled through the
hole. The acreage of workspace required can increase significantly if grading is required to reduce the
slope across the site. Installation of storm water management controls will also increase the footprint for
sites with steep slopes. Furthermore, the entry-side equipment typically includes the drilling rig, control
cab, drill string pipe storage, site office and tool storage trailers, power generators, bentonite storage,
bentonite slurry mixing equipment, slurry pump, cuttings separation equipment, cuttings return/settlement
pit, water trucks and water storage, and the heavy construction equipment necessary to support the
operation.
Topography is also a risk as the pipe is prepared for pullback operations. Steep slopes limit the amount of
stringing areas and therefore increase the number of strings to be pulled through the drill hole. A single-
string pull-back is preferred for HDDs because it avoids the need to stop the pullback activity to weld up
separate pipe strings. A single tie-in weld can take up to eight hours to complete and apply protective
coating. The longer the hole is left open without the pipeline in it, the greater the chance of a collapse of
the drill hole. A single string pullback allows for a continuous force to be applied to the pipe during the
pullback, and reduces the risk of the pipeline becoming stuck in the borehole (due to the potential for a
localized collapse of the borehole around the pipeline, and soil set up around the pipe).
Transco views safety as a top priority. Per company Job Safety Analysis (JSA) policy and in accordance
with Occupational Safety and Health Administration (OSHA) regulations, Transco has identified general
safety hazards associated with HDD crossings. These include high pressure hydraulic fluid hoses, rotating
equipment, pinch points, and elevated noise levels. Transco is committed to protecting the safety of both
Company and contractor personnel by minimizing exposure to hazards. All stream crossing methods,
including open-cut crossings, pose unique safety hazards. These hazards may be eliminated or mitigated
through proper use of safety controls and personal protective equipment. However, the projected duration
of the HDD process is significantly higher than the duration of an open-cut crossing.
HDDs require several teams working in tight spaces, near operating equipment, with their own separate
tasks, and incidents can occur when there is not adequate communication due to all of these different teams
working individually. This also increases the number of construction vehicles on-site, congesting the
necessary workspace while creating concerns of foot traffic. The stringing and lifting of the pipe high into

the air to adequately align the pipe into the hole causes danger from overhead and the rollers (both on the
ground and on the cranes) cause many of the several other locations of pinch points.
4.2.2 Elevation Differential and Dry Hole
Elevation differential between the entry and exit points is a high risk factor to the success of an HDD,
as terrain and landowner constraints will drive entry and exit locations. During HDD construction, a
high elevation differential can result in the drilling fluid within the hole coming to equilibrium at the
lower of the two points, causing a portion of the hole to be situated above the drilling fluid equilibrium
elevation. This condition creates a “dry” section within the hole, which can increase the risk of hole
collapse, groundwater intrusion and poor cuttings removal from the hole which, in turn may lead to
additional risks (ground settlement, loss of drilling fluid returns, inadvertent returns, hole flushing, stuck
tool/pipe).
If geotechnical investigations find high groundwater, this suggests a “dry” hole may experience
groundwater intrusion that will flow towards the low (entry) side of the crossing. This will present a high
risk of dilution of drilling fluids, inability to transfer cuttings out of the hole, sinkhole formation, and hole
instability and collapse. Gravelly and large-grained soils can also lead to hole instability and collapse. This
risk is mitigated, to a degree, by the presence of drilling fluid. However, where drilling fluids are
lacking in areas of “dry” hole, this risk is more acute. The “dry” hole condition will likely result in a risk
of cuttings buildup within the hole. The stability of the “dry” hole section may be improved by installing
dewatering wells near the HDD alignment and/or through the installation of large diameter
casing. However, casing may be difficult to drive to the extent needed to fully mitigate the risk, and
dewatering may only be partially effective to control groundwater intrusion. Consideration to dewatering
locations adds complexity to maintaining compliance.
4.2.3 Hole Stability
The stability of the hole during HDD operations is dependent on the type and composition of the formation,
drilling fluid properties, groundwater conditions and the HDD profile geometry. Holes drilled or reamed
through loose soil formations, soil formations with significant gravel content, or fractured rock formations
with poor rock mass quality are prone to instabilities.
Soil Portions of the HDD Profile
Where granular soils are encountered within the hole, particularly if they lack a significant fine-grained
matrix to support hole integrity, they may tend to ravel and collapse the hole. Installing large diameter
casing through sections with non-cohesive soils can partially mitigate these risks. However, casing may
be difficult to install to the extents required to mitigate the risks.
Rock Portions of the HDD Profile
The possible loss of hole stability through zones of highly fractured bedrock cannot be mitigated with a
high level of confidence. An extensive grouting program to improve the rock mass characteristics could
be attempted, however, the grouting is unlikely to be effective at stabilizing the formation. The aim of the
grouting program would be to seal the fractures in the bedrock in an effort to stabilize the formation prior
to the commencement of HDD operations. For the grouting program to be effective, numerous closely
spaced holes would need to be drilled down vertically from the surface to the depths of the HDD profile
and the grout would need to be injected at several depth intervals within each hole to attempt to create a
zone of improvement.

4.2.4 Obstructions
As discussed above, the HDD profile could potentially pass through soil zones that contain significant
volumes of gravel, cobble, and boulder-sized materials. These granular soils can present risk to HDD
operations in addition to of the risk of hole stability described above. Even if the soil contains sufficient
fine-grained matrix (silt and clay) to maintain hole stability in gravelly soils, gravel and larger-sized rock
particles within the cross section of the hole are too large to be carried out of the hole by the drilling fluid
during pilot hole, reaming and swabbing operations. This can lead to an accumulation of this coarse
material within the hole. In some instances, this material can be pushed aside into the wall of the hole or
be broken down into smaller particles during subsequent reaming and swabbing operations. The denser
the formation, the less likely the larger particles will be pushed into the walls of the hole. The portion
of this material that is not pushed aside or broken down can create difficulties during pullback operations
and may cause the product pipe to become lodged in the hole or damage the product pipe during
pullback. This effect may range from sudden to gradual depending on the location and volume of
accumulated material.
In addition to the accumulation of large particles downhole, the bottom hole assembly (BHA) and/or
reaming tools may be deflected around cobble and boulder-sized material partially protruding into the cross
section of the hole. During pilot hole operations, this can result in radii of curvature below the acceptable
minimum and increase the amount of time necessary to complete the pilot hole within acceptable
tolerances. As a reaming tool moves past these obstacles and returns to its original path, a localized
deviation in the geometry of the hole may be formed. These localized deviations can create difficulties
during pullback operations depending on their location, magnitude and frequency. More specifically, these
locations become “hard” points that are more likely to: (1) damage the coating and/or product pipe during
pullback operations; (2) increase the pull load required to install the product pipe; and (3) cause the
product pipe to become stuck in the hole because it is unable to conform to the shape of the resulting hole
geometry.
4.2.5 Pilot Hole Steering
Steering difficulties can arise during pilot hole operations if the drill bit penetrates through layers of gravelly
soil consisting cobble or boulder-sized material and/or rock units of varying strength and quality along
the HDD profile. Developing a suitable steering pattern during pilot hole operations can be challenging. It
may take drilling 60 to 100 feet of t h e pilot hole before the pilot hole surveyor can determine how the
BHA will react to the operator’s prescribed steering inputs. By the time a steering pattern is developed,
the formation may have changed and the steering pattern becomes either ineffective or too aggressive.
Once the geometry of the pilot hole begins deviating from the specified vertical or horizontal tolerance
and/or the minimum horizontal and vertical curve radius tolerances, it can be difficult and time consuming
to correct the deviation when drilling through gravelly soils or rock. If the pilot hole deviates outside the
horizontal or vertical tolerances it may be preferable to accept the out of tolerance condition and continue
drilling the pilot hole if the condition will not adversely impact the installation of the product pipe or its
performance, once installed. If the out-of-tolerance condition is not acceptable, the HDD contractor will
have to extract the tooling back to a location in the hole where it would be possible to “kick out” of the
existing hole and begin drilling new pilot hole. If the pilot hole radius of curvature deviates from the
minimum allowable radius, the HDD contractor would need to retract and attempt to correct the section
of the hole that is out of specification or “kick out” and begin drilling new pilot hole, which in bedrock,
can take a significant period of time.

To aid in steering the BHA during pilot hole operations, the contractor can vary the components of the
BHA to provide either more aggressive or less aggressive steering bias. The HDD contractor may also
utilize a specialized tool as part of the BHA that can measure the inclination at the drill bit as well as at
the steering probe. This can help the pilot hole surveyor more quickly judge how well the BHA is reacting
to his prescribed steering inputs. If the HDD contractor is willing to make changes to the components of
the BHA to better suit the conditions, we estimate that the risk of excessive steering problems may be reduced
from high to moderate.
4.2.6 Drilling Fluid Loss, Hydraulic Fracture and Inadvertent Returns
Drilling fluid loss can occur as a result of either formational fluid loss or hydraulic fracture. The loss of
drilling fluid downhole is accompanied by either partial or full loss of drilling fluid returns to the entry
and/or exit pits. Hydraulic fracture is a term typically used to describe the condition in which the
downhole drilling fluid pressure exceeds the overburden pressure and shear strength of the formation
surrounding a drill path. The risk of hydraulically fracturing subsurface formations during the HDD
process generally depends on the type and shear strength of the formation and the downhole drilling fluid
pressures. Downhole drilling fluid pressures can easily exceed the shear strength of soil formations;
however, rock formations normally have shear strengths far exceeding typical drilling fluid pressures, and
therefore, the risk of hydraulically fracturing rock formations is low.
Inadvertent drilling fluid returns occur when drilling fluid emerges at the ground surface or in any
other undesired location such as wetlands, utility trenches, roads, railroads and water bodies. Inadvertent
drilling fluid returns may occur either as a result of hydraulically fracturing the subsurface formations or
as a result of formational fluid loss. In rock formations the risk of formational fluid loss is greater than
that of hydraulic fracture. Whether by formational drilling fluid loss or hydraulic fracture, relatively large
volumes of drilling fluid may be released over a short period of time, particularly if the high pressure
drilling fluid pumps are not immediately disengaged. Once inadvertent drilling fluid returns occur, it
can be difficult to prevent fluid from continuing to surface. Transco anticipates moderate to high risk of
inadvertent returns near the entry and exit points of any HDD where the depth of soil cover above the
HDD is relatively low. The management of the drilling fluid properties and construction methods to
promote proper drilling fluid returns help to reduce the risk of inadvertent drilling fluid returns near the
entry/exit points.
4.2.7 Poor Cuttings Removal
An important aspect of the HDD process is the removal of cuttings from the annulus of the hole. If drilling
fluid returns are lost to the formation, the likelihood of cuttings accumulating in the hole is
significant. If soil and rock cuttings are not adequately removed from the hole, several additional risk
factors can negatively impact the likelihood of a successful pipeline installation. When cuttings build up
within the hole, rotary torque on the drill pipe string can increase, tool wear is increased, the risk of drilling
fluid loss and subsequent inadvertent drilling fluid returns is increased as is the risk of hole flushing. At
worst, the accumulation of cuttings downhole can cause the downhole tooling to become stuck, cause a
twist-off downhole or cause the pipeline to become lodged in the hole during pullback operations. To
decrease the risk of cuttings buildup downhole and the associated risk factors, the HDD contractor could
complete reaming operations in a staged approach from both sides of the crossing (bi-directional reaming)
to help promote drilling fluid returns and cuttings removal from the hole and reduce the risk of lost drilling
fluid returns, inadvertent returns and hole flushing.

4.2.8 Hole Obstructions and Flushing
If the hole becomes obstructed with gravel or cuttings generated during pilot hole or reaming operations,
the drilling fluid level in the hole can begin to rise above the low end of the crossing into the normally dry
portion of the hole. The drilling fluid will often continue to rise in the dry section of the hole until the
hydrostatic pressure within the hole causes a breach in the obstruction and the drilling fluid level in the
hole begins to equalize. This condition is referred to as a “hole flush”. Depending on the diameter of the
hole and the height of the drilling fluid above the low side of the crossing when the hole flushes, the volume
of drilling fluid that is expelled from the hole can be significant. The volume of drilling fluid expelled
during the hole flush may impact sensitive areas outside of the designated workspace areas or the sensitive
feature that was being avoided by use of the HDD.
4.2.9 Downhole Tooling Failure / Loss
Tooling failure can be caused by many factors including metal fatigue, general wear, improper make-up
of tool joints, and abnormally high operating loads or misuse. When tooling is lost downhole, recovery
efforts may or may not be successful. Downhole tooling used to complete the project will be subjected to
high stresses and be more prone to metal fatigue and ultimately failure downhole with the presence of
boulders and gravelly soil conditions, fractured zones of bedrock and hole instabilities.
4.2.10 HDD Time of Installation
Duration from site preparation to pipe tie-in and dependent on subsurface conditions, the HDD can take
more than 6 months. Upon initiation of the HDD pullback, operation will continue twenty-four hours a
day until the pipeline is pulled though the drill hole.
If encountered, hard bedrock can significantly lengthen the pilot hole and reaming process. Similarly, if
cobbles/boulders or highly fractured rock is encountered along the drill path, then these soils could become
dislodged and obstruct the drill, necessitating multiple drill attempts. Similarly, boulders can deflect the
pilot drill bit and push the drill off of the desired alignment, also resulting in multiple drill attempts to get
past the obstruction.
Surface terrain constraints also pose significant challenges to HDD installations. If multiple pullback strings
are needed due to road crossings, changes in pipeline alignment, topographic constraints, etc., then the
duration of the crossing is also increased. Additional risk can also be realized if multiple pullback strings
are needed in that the pullback process must be stopped so that tie-in welds can be completed and
protective coatings applied and allowed proper time to cure. The longer that the pullback string remains
stationary downhole, the greater the pull force will be needed to break the stiction of the soil set up around
the pipe. The stiction forces can become high enough that the pipe could become stuck part-way in the hole
or break the drill pipe, requiring abandonment and restarting the HDD in another location.
4.3 HDD Environmental Factors
Drill hole failure (collapse of the drill hole) during drilling or pipeline pullback operations is one of the
greatest risks to the successful completion of a HDD. A drill hole failure can cause an accidental release
of drilling mud to the surface. If an inadvertent return of drilling mud takes place within the stream it could
increase turbidity and sedimentation within the stream and migrate downstream, thus potentially altering
the habitat at, and downstream of, the site of disturbance. HDDs require a greater amount of equipment
than is required for trenched installation of the pipe. Large-diameter pipeline (e.g., 30- to 42-inch) HDDs
typically require 90,000 to 100,000 gallons of water per day for use in the creation of drilling mud. If

surface water is not available at the site, it must be identified and trucked in daily from a municipal water
source. This increase in equipment onsite could increase the amount of the impacts due to traffic. The
drilling mud is used to lubricate the drill stem as well as return cuttings to the surface for collection and
disposal.

5.0 SUMMARY OF CONSTRUCTION METHODS FOR ATLANTIC SUNRISE
Table 1: Summary of Construction Methods for the Atlantic Sunrise Project
Typical Duration
Maximum Minimum Typical Workspace Cost to Construct 1,600
Compared to Dry
Type Distance Distance Requirements Linear feet with One 30- Advantages Limitations Risks
Open Cut
(feet) (feet) (square feet) feet Stream Crossing b/
Construction a/
90 feet wide x length of

Typically 24 to 48 hours High probability of success and
crossing – 42-inch pipe Seasonal restrictions; flow rates may necessitate a wet-
Dry Open Cut N/A N/A from start of excavation $902,000 minimal impacts using best Unanticipated weather events
80 feet wide x length of open cut or trenchless (as terrain allows)
through restoration management practices.
crossing – 30-inch pipe
Five times slower than Avoidance of resource; best Safety constraints related to excavation and shoring of bore pit
Conventional 10,000 (entry and exit pit Limited by crossing distance, subsurface soil and geologic
300 N/A typical durations for $1,302,000 suited for short crossing locations. Potential drill failure resulting in abandonment and
Bore workspace) conditions, existing topography, and groundwater.
open cut excavations distances. re-drill, or implementation of an open cut design.
Geotechnical investigations requiring access road

development, and potential tree clearing, wetland and
100,000 (entry and exit pit waterway crossings prior to pipeline construction. Large Potential inadvertent returns of drilling fluids; Additional
1,280 d/ for
7,000 for workspace) as well as workspace requirements for entry and exit locations. workspace for access and mitigation; Potential hole collapse
30-inch pipe
30-inch additional false ROW for pull- 20 times slower than Avoidance of resource; best Continuous day and night noise disturbances associated or subsequent settlement following installation; Potential drill
Horizontal
back locations. False ROW is typical durations for $5,600,000 suited for significant crossing with drilling equipment, generators, water and drill fluid failure resulting in abandonment and implementation of an
Directional Drill 1,700 d/ for
6,000 for generally 100-150 feet wide open cut excavations lengths. pumps, construction vehicles and ancillary equipment. open cut design; Future repair work may necessitate the HDD
42-inch pipe
42-inch with a length dictated by the Water consumption for drilling operations, and disposal segment to be abandoned in place, and another HDD
crossing segment. requirements for drilling fluids. Pipeline inaccessible for installed.
visual inspection and repairs. Potential uneven cathodic
protection on the pipeline.
a/ Estimated durations for construction include the time necessary for workspace setup, construction and restoration when compared to typical open cut surface trenching operations.
b/ Costs provided for construction were based on actual construction contractor bids received for the Atlantic Sunrise Project. All costs provided are for 42-inch pipeline work. For Dry Open Cut and Conventional Bore, costs include 1,570 feet of upland construction to achieve an apples-to-apples comparison
with the 1600’ HDD length.
c/ Estimates of typical workspace requirements are based on past Transco natural gas transmission projects and current proposed workspace configurations for Transco.
d/ Minimum distance is a function of the maximum allowable radius of curvature as well as site-specific topography. If the elevation of the resource being avoided is higher than the HDD entry and exit locations, the shorter length presented herein can be achieved. Lower resource elevations, relative to the
entry and exit elevations, will yield longer minimum lengths.

6.0 RESOURCE CROSSING EVALUATION METHODOLOGY
6.1 Overview
As the lead federal agency with ultimate jurisdiction over the siting of the CPL pipeline, FERC reviews
Transco’s preferred alignment as well as multiple alternatives to determine the least impactful alternative
with respect to environmental resources including wetlands and waterways as well as other factors such as
landowner impacts and constructability.
The use of trenchless construction methods is not feasible or practical for every wetland or waterway
crossing. Trenchless construction methods can be limited by topography, unfavorable underlying geology,
available workspace, available time (i.e., limited construction windows), and the inherent risks associated
with use of trenchless construction methods, including extended crossing times and potential remediation
of inadvertent drilling mud releases or drill failures. All of these factors must be considered to determine
if trenchless construction methods are a suitable option for crossing a specific resource.
When examined in aggregate, the quantity of trenchless crossings that may be adopted are further
constrained by the availability of qualified contractors that have the required equipment
available. Although skilled labor and equipment availability are considerations that must be evaluated,
Transco has attempted to focus this analysis on the technical feasibility of trenchless installations,
environmental effects, and other risks. A flow chart depicting the phases of the analysis used is provided
in Appendix B. A description of each phase is further defined within this Section below.
6.2 Conventional Bore Assessment for Waterways
Phase I: Resource Characteristics
Transco will make reasonable efforts to cross streams classified as “ephemeral” or “intermittent” during
periods of no flow, resulting in minimal disturbances to dry channels which would presumably be restored
prior to the return of flow. Additionally, as noted in Table 1, the associated workspace requirements to
implement a trenchless crossing would present a greater overall impact to the surrounding area when factors
such as equipment mobilization, site clearing, water allocations, durations and site restoration are compared
to the workspace requirements and procedures to complete a dry crossing. The majority of intermittent
streams to be crossed are less than five feet in width which allows for an expedited crossing without the
need for significant areas of additional temporary workspace. Intermittent stream crossings will be
completed and restored within 24 hours. Water quality within these resources will be protected by
constructing during periods of no or low flow. Should an intermittent stream contain flowing water at the
time of construction, a dry-crossing technique will be used. For these reasons, it was determined that
impacts are sufficiently minimized using a typical construction method for ephemeral and intermittent
features, and only streams designated as perennial continued to Phase II of the assessment.
Similarly, Transco did not consider the conventional bore crossing technique for wetland crossings because
there are minimal impacts using a dry open cut construction technique. Clearing within the permanent
ROW would be required during operation of the pipeline to ensure that root systems of trees do not
compromise the pipe coating, and to allow for aerial inspection of the alignment. Because a swath would
be cleared during construction and maintained during operation (even if a conventional bore were
completed), there would be minimal impact reductions to the resource by utilizing the conventional bore
installation method versus an open cut. However, there would be significant increases in impacts to

resources outside of the wetlands to accommodate the workspace required for a bore. Therefore
conventional bores are not practical for avoiding wetland resources.
Phase II: Topography Assessment
Transco evaluated site-specific topography to determine if bore pits could be constructed in a safe manner,
as previously discussed in Section 3.2.5. The following Figure 1 is a simplified plan view of a bored
crossing.
Figure 1: Bore Pit Placement, Plan View
Note that the bore pits, both entry and receiving, are approximately 70 feet long for a typical 30-inch boring
in ideal conditions. Bore pits are offset from floodway boundaries by a minimum 20 feet on each side to
prevent any potential impacts to the floodways while the pits are being excavated or while the bore is being
conducted. Bore pits may have to be further offset from the stream to avoid placement in wetlands, as
depicted by the receiving pit in Figure 1.
Maximum Bore Length
The maximum distance that a bore can be completed is 300 feet. This distance is lower if soil conditions
lend themselves to a higher skin friction that the pipe must overcome as it is pushed through the bore
annulus. The potential bores with a bore length less than 300 feet continued to the bore pit depth
assessment.

Figure 2, below, demonstrates elevation considerations via a profile view of a bore pit.
Figure 2: Bore Pit Depth - Determining Factors
Where:
‐ HEP = depth of the entry pit

‐ HRP = depth of the receiving pit
‐ EPfront = grade elevation at the entry pit’s front face
‐ EPback = grade elevation at the entry pit’s back face
‐ RPfront = grade elevation at the receiving pit’s front face
‐ RPback = grade elevation at the receiving pit’s back face
‐ S = location of stream bed where the pipeline crosses
‐ YEP = difference in elevations between the top of the entry pit and the stream bed. For the entry
pit elevation, use the higher elevation of EPfront or EPback
‐ YRP = difference in elevations between the top of the receiving pit and the stream bed. For the
receiving pit elevation, use the higher elevation of RPfront or RPback
‐ D = pipeline diameter
‐ C = clearance between stream bed and top of pipe
‐ F = clearance between bottom of pipe and the bore pit floor
‐ L = horizontal length of the bore
Maximum Bore Pit Depth
Both Williams Onshore Construction Safety Handbook and the OSHA Pocket Guide for Excavations
require engineering design and approval for bore pits that are deeper than 20 feet. At this depth, standard
trench boxes are not tall enough to protect the integrity of the pit walls, and significant benching and spoil
storage will be required, thereby necessitating a larger footprint for workspace.
Transco used the following methodology to determine bore pit depth:
 Identify the elevations associated with both faces of both bore pits
 Identify the elevation for the stream bed, S
 Calculate YEP and YRP by finding the difference between bore pit grade elevations and stream bed
elevations.

 Assume 5 feet minimum clearance between the top of pipe and the stream bed, C. Actual clearance
requirements may be greater if less-than-ideal subsurface conditions are identified by geotechnical
investigations.
 Identify the clearance between bottom of pipe and the bore pit floor, F. This clearance is needed
to complete tie-in welds, and the minimum clearance is approximately 2 feet.
 Calculate the bore pits depths using the formulas below:
C D F 20
20
Based on this methodology, bores with entry and exit pits less than 20 feet in depth continued to Phase III
of the assessment.
Phase III: Desktop Risk and Impacts Assessments
This phase involves an assessment of the risks and environmental effects of the potential bores. The
determination regarding the feasibility of the potential bores evaluated in Phase III is based on the
assessment of the factors listed below.
Phase 3A: Impacts Assessment
After verifying that the site topography could accommodate a conventional bore at a particular crossing,
Transco developed the site-specific workspace associated with implementation of the crossing
technique. The associated footprint is heavily influenced by spoil storage requirements, grading
requirements, and soil conditions.
Phase III includes activities that allow Transco to assess the crossing from a multi-disciplinary perspective.
Once developed, the workspace associated with a bore was then compared to the workspace associated with
the current crossing technique to compare impacts. Impacts were compared based on the following criteria:
 Wetland Acreage
o PFO
o PEM
o PSS
 Upland Acreage
 Land Use
 Anticipated construction durations
 Transco also reviewed affected landowners including those that would be impacted by incremental
workspace requirements.
 Other
A given location may have other considerations, outside of the PADEP regulatory purview, that Transco
must take into consideration when determining practicality. One such example is landowner willingness

to provide additional workspace that a bore may require. In recent projects, FERC has denied variance
requests where landowner concurrence could not be obtained.
Phase 3B: Risk Assessment
In addition to the construction risks inherent to conventional bores, as discussed in Section 3.2, Transco
also assessed other risk criteria that are dependent upon site-specific conditions, including:
 Blasting that may be required through shallow rock to achieve bore pit depths
 Geological hazards, including but not limited to karst formations
 Nearby public or private water intakes, such as wells springs.
Using the impacts and risk assessments, qualitative assessments completed under Phase III are compiled
into site-specific narratives for each potential conventional bore crossing. A determination about the
feasibility of a conventional bore for each crossing is made based on these assessments.
Phase IV: Geotechnical Investigation
Geotechnical investigations will be conducted where access is granted to verify whether or not subsurface
conditions can accommodate all conventional bores deemed feasible in the Phase III analysis. Geotechnical
investigations are usually completed using a track-mounted drill rig. Access to the bore locations may also
require crossing of regulated resources that may result in temporary impacts, and therefore Transco may
have to apply for permits and clearances for the activity. These general permits/clearances can take several
months to procure and also require landowner approval prior to conducting the subsurface investigations.
Where geotechnical results indicate subsurface soil conditions are conducive to a conventional bore
crossing, those waterways were then moved as a group for a programmatic assessment of skilled labor and
equipment availability.
6.3 HDD Assessment for Wetlands and Waterways
Phase I: Resource Classification
An HDD was not evaluated for waterways where a conventional bore was deemed feasible, as Project-
related impacts to the waterway would be avoided.
Analysis of High Quality / Exceptional Value Waterways and Wetlands
Transco has investigated the use of HDD construction for wetlands and waterways designated as High
Quality (HQ) or Exceptional Value (EV) by PADEP under Chapter 93. Features without these designations
were not considered for crossing via HDD based on the less sensitive nature of the resource with respect to
water quality and fisheries resources. The use of standard dry-crossing construction techniques and
adherence to Transco’s ECP will fully protect these resources and maintain their water quality designations.
Phase II: Feature Characteristics
Forested Wetlands with Impacts that Exceed One Acre
A preliminary desktop analysis of the forested wetlands designated as HQ or EV with Project-related

impacts resulting in greater than 1.0 acres of disturbance was conducted to evaluate the logistics and

feasibility for use of a trenchless crossing method. Individual wetland crossings resulting in greater than
1.0 acre of disturbance in Pennsylvania which would exceed United States Army Corp of Engineers
(USACE) and state permitting agency thresholds for a State Programmatic General Permits.
Transco found that HDDs are not practical for non-HQ/EV wetlands, or for wetlands that have PFO impacts
less than 1 acre. For such wetlands, a dry open cut construction technique has minimal impacts, and the
additional workspace, construction duration, and cost associated with an HDD are not warranted.
HQ or EV wetlands with PFO impacts greater than 1 acre, advanced to Phase III.
Minimum Crossing Distance for Waterways
Because of the substantial risks and environmental factors, previously reviewed in Sections 4.2 and 4.3,
respectively, HDDs are typically reserved for major waterways or highway crossings, where other means
of construction are not feasible based on site-specific conditions. For waterways, this typically relates to a
crossing width of 100 feet or greater.
Implementation of a trenchless crossing for waterways less than 30 feet in width that are independent of
adjacent wetland and waterway resources have the potential to require workspace requirements
significantly greater than the typical impacts that would generally occur for a conventional dry crossing
method. Typical workspace requirements to conduct a dry crossing for a 30-inch pipeline for a minor
waterway (30 feet or less in width) generally do not involve a temporary disturbance greater than 24,000
square feet (approximately 76% less workspace than the typical requirements for an HDD). Use of an HDD
would require a minimum crossing distance of approximately 1,280 linear feet and would result in
approximately 100,000 square feet of clearing and surface disturbances plus additional disturbances for
false ROW pullback locations (generally a 100-150 feet wide and a length similar to the distance of the
crossing).
Due to the minimum crossing requirements for HDD construction methods, Transco did not evaluate
waterway crossings less than 30 feet in width unless the feature was determined to be immediately
associated with a larger waterway complex crossed by the Project; or the feature was determined to be
located in the immediate vicinity of a proposed rail or roadway crossing. Additionally, waterways not
directly crossed by the pipeline (located in workspace only) were not evaluated for trenchless construction
methods. And similar to the Phase I assessment for conventional bores, only perennial waterways were
considered for HDD.
HQ/EV perennial waterways that are greater than 30 feet in width advanced to Phase III.
Phase III: Assess Impacts, Risks, and Landowners
Next, Transco developed the HDD profile and site-specific workspace. The associated workspace footprint
is heavily influenced by spoil storage requirements, grading requirements, and soil conditions.
Phase 3A: Impacts Assessment
The workspace associated with the HDD was then compared to the workspace associated with the current
crossing technique to compare impacts. Impacts were compared on the following criteria:
 Wetland Acreage

o PFO
o PEM
o PSS
 Upland Acreage
 Land Use
 Water Consumption
 Noise generated by construction equipment
 Air emissions generated by construction equipment
 Anticipated construction durations
 Other
Transco also reviewed affected landowners, and those that would be impacted by incremental workspace
requirements were consulted.
A given location may have other considerations, outside of the PADEP regulatory purview, that Transco
must take into consideration when determining practicality. One such example is landowner willingness
to provide additional workspace that an HDD may require or the necessary permissions to access the
property for the necessary geotechnical investigations. FERC will deny variance requests where landowner
concurrence could not be obtained.
Phase 3B: Risk Assessment
There are numerous site-specific construction risks associated with an HDD, as outlined in Section 4.2.
Transco also assessed other risk criteria that are dependent upon site-specific conditions including
proximity to public or private water intakes such as a well or spring. Perhaps the most notable risk facing
the HDD construction method is the availability of the HDD equipment and skilled labor to operate the
equipment. There are a limited number of HDD contractors capable of completing large diameter crossings,
and those contractors are typically in high demand. Contractors are limited to the amount of equipment,
and the expertise that they may have available at any given time. If awarded several individual HDD
crossings on a single project such as Atlantic Sunrise, an HDD contractor will likely have to complete the
HDDs sequentially, rather than concurrently, which can significantly influence the schedule and potentially
compromise the FERC-certificated in-service date. Numerous other large-diameter pipeline projects are
scheduled to be in construction in 2017-2018 which will limit the number of qualified contractors available
to complete all of the associated HDD work. In fact, all contractors that have bid to perform work for
Atlantic Sunrise have identified skilled labor and equipment constraints in their responses with respect to
HDD’s.
The qualitative assessments completed under Phase III are compiled into site-specific narratives for each
potential HDD crossing. A determination about the feasibility of an HDD for each crossing is made based
on these assessments.
Using the impacts and risk assessments, Transco was able to draw a conclusion regarding the overall
feasibility of completing an HDD crossing. All HDDs deemed feasible were then scheduled for
geotechnical analysis of the subsurface conditions.

Phase IV: Geotechnical Investigation
Geotechnical investigations will be conducted to verify whether or not subsurface conditions can
accommodate a HDD. Where geotechnical results indicate subsurface soil conditions conducive to a HDD
crossing, those waterways were then moved as a group to the programmatic review.
6.4 Equipment and Skilled Labor Assessment
All trenchless crossings that were deemed practical will then be evaluated as a program, to determine if
sufficient skilled labor and equipment resources were available to complete the quantity of trenchless
crossings deemed practical / feasible. Because trenchless crossings are highly technical, experienced
contractors are critical to realizing successful installations. Where a qualified contractor may note
symptoms of a potential issue and take corrective action, an inexperienced contractor may allow a risk to
manifest, instead of being mitigated.
7.0 RESULTS OF TRENCHLESS CROSSING ANALYSIS –

SUSQUEHANNA COUNTY
7.1 Conventional Bores
All streams crossed in Susquehanna County are presented in Table 2. Conventional boring was not found
to be a practical construction technique for all these streams, primarily due to stream characterizations of
‘ephemeral or intermittent’, as well as topography challenges that yielded deep bore pits. Of the 13 streams
impacted in Susquehanna County, 6 did not pass Phase I assessments (were not perennial), and 7 did not
pass Phase II (topography could not accommodate bore length and/or bore pit depth limitations).
7.2 HDDs
All streams crossed in Susquehanna County are presented in Table 3, and all wetlands are presented in
Table 4. HDD was not found to be a practical construction technique in Susquehanna County as there were
no HQ streams that were wider than 30 feet. There were also no EV wetlands with PFO impacts greater
than 1 acre (nothing passed Phase I/II).
7.3 Geological Assessments
Geological assessments will not pursued in Susquehanna County as a part of this assessment because no
features are suitable for trenchless crossings.
8.0 RESULTS OF EQUIPMENT / SKILLED LABOR ASSESSMENT

Susquehanna County does not have any planned conventional bores or HDDs for wetlands or waterways,
and therefore an equipment and skilled labor availability assessment was not conducted for this county. All
crossings can be constructed with the current proposed method.

Table 2: Waterways Assessed for Conventional Bores
State Water Quality

Crossing FERC State Fishery Crossing Crossing
Resource ID Waterbody Name Milepost Stream Type Use Classification – Conventional Bore Summary
Width (feet) Classification Classification Window Method
Designated Use
UNT to Willow Jan. 1– Perennial Stream. Bore length 191 ft. Bore pit depths are 25 ft & 22 ft. This stream
WW-T30-21001 51.4 17.25 Perennial Minor CWF, MF Wild Trout Waters Dam-and-pump
Brook Sept. 30 was not further considered for conventional bore.
UNT to Willow N/A Jan. 1– Stream type is Intermittent and the centerline does not cross the stream. This
WW-T12-21004A 51.7 NA Minor CWF, MF Wild Trout Waters NA
Brook Intermittent Sept. 30 stream was not further analyzed.
UNT to Willow Jan. 1– Perennial Stream. Bore length 242 ft. Bore pit depths 93 ft & 75 ft. This stream
WW-T12-21004 51.7 37.3 Perennial Intermediate CWF, MF Wild Trout Waters Dam-and-pump
Brook Sept. 30 was not further considered for conventional bore.
Jan. 1– Perennial Stream. Bore length 119 ft. Bore pit depths are 54 ft & 109 ft. This
WW-T12-21001 Willow Brook 52.4 34.75 Perennial Intermediate CWF, MF Wild Trout Waters Dam-and-pump
Sept. 30 stream was not further considered for conventional bore.
Jan. 1–Sept. Perennial Stream. Bore length 210 ft. Bore pit depths are 60 ft & 52 ft. This stream
WW-T50-21001 Utley Brook 53.4 26.73 Perennial Intermediate CWF, MF Wild Trout Waters Dam-and-pump
30 was not further considered for conventional bore.
Jan. 1– Perennial Stream. Bore length 198 ft. Bore pit depths are 47 ft & 42 ft. This stream
WW-T50-21002 Millard Creek 54.1 26.87 Perennial Intermediate CWF, MF Wild Trout Waters Dam-and-pump
Sept. 30 was not further considered for conventional bore.
UNT to Millard Jan. 1–Sept.

WW-T50-21003 54.1 7.57 Intermittent Minor CWF, MF Wild Trout Waters Dam-and-pump Stream type is Intermittent. This stream was not further analyzed.
Creek 30

WW-T12-21007 55.1 5.32 Intermittent Minor CWF, MF Wild Trout Waters Dam-and-pump Stream type is Intermittent. This stream was not further analyzed.
Creek 30

WW-T12-21007A 55.1 5.04 Ephemeral Minor CWF, MF Wild Trout Waters Dam-and-pump Stream type is Ephemeral. This stream was not further analyzed.
Creek 30
UNT to Tower Jan. 1–Sept.

WW-T92-21002 M-0061 0.1 3.63 Ephemeral Minor CWF, MF Wild Trout Waters Dam-and-pump Stream type is Ephemeral. This stream was not further analyzed.
Branch 30
UNT to Tower Jan. 1– Perennial Stream. Bore length 71 ft. Bore pit depths are 23 ft & 27 ft. This stream
WW-T12-21009A M-0061 0.1 15 Perennial Minor CWF, MF Wild Trout Waters Dam-and-pump
Branch Sept. 30 was not further considered for conventional bore.
Jan. 1– Perennial Stream. Bore length 168 ft. Bore pit depths are 26 ft & 31 ft. This stream
WW-T48-21001 Tower Branch 56.8 17.96 Perennial Intermediate CWF, MF Wild Trout Waters Dam-and-pump
Sept. 30 was not further considered for conventional bore.
UNT to Tower Jan. 1–

WW-T17-21001 57.2 7.38 Ephemeral Minor CWF, MF Wild Trout Waters Dam-and-pump Stream type is Ephemeral. This stream was not further analyzed.
Branch Sept. 30

Table 3: Waterways Assessed for HDD
State Water
Waterbody Crossing FERC HQ / EV Quality Use State Fishery Crossing
Resource ID Milepost Stream Type Crossing Method HDD Summary
Name Width (feet) Classification (Yes/No) Classification – Classification Window
Designated Use
UNT to Willow
WW-T30-21001 51.4 17.5 Perennial Minor No CWF, MF Wild Trout Waters Jan. 1–Sept. 30 Dam-and-pump Stream type is not HQ. This stream was not further analyzed for HDD.
Brook
UNT to Willow N/A

WW-T12-21004A 51.7 NA Minor No CWF, MF Wild Trout Waters Jan. 1–Sept. 30 NA Stream type is not HQ. This stream was not further analyzed for HDD.
Brook Intermittent
UNT to Willow
WW-T12-21004 51.7 37.3 Perennial Intermediate No CWF, MF Wild Trout Waters Jan. 1–Sept. 30 Dam-and-pump Stream type is not HQ. This stream was not further analyzed for HDD.
Brook
WW-T12-21001 Willow Brook 52.4 34.75 Perennial Intermediate No CWF, MF Wild Trout Waters Jan. 1–Sept. 30 Dam-and-pump Stream type is not HQ. This stream was not further analyzed for HDD.
WW-T50-21001 Utley Brook 53.4 26.73 Perennial Intermediate No CWF, MF Wild Trout Waters Jan. 1–Sept. 30 Dam-and-pump Stream type is not HQ. This stream was not further analyzed for HDD.
WW-T50-21002 Millard Creek 54.1 26.87 Perennial Intermediate No CWF, MF Wild Trout Waters Jan. 1–Sept. 30 Dam-and-pump Stream type is not HQ. This stream was not further analyzed for HDD.
UNT to Millard
WW-T50-21003 54.1 7.57 Intermittent Minor No CWF, MF Wild Trout Waters Jan. 1–Sept. 30 Dam-and-pump Stream type is not HQ. This stream was not further analyzed for HDD.
Creek
UNT to Millard
WW-T12-21007 55.1 5.32 Intermittent Minor No CWF, MF Wild Trout Waters Jan. 1–Sept. 30 Dam-and-pump Stream type is not HQ. This stream was not further analyzed for HDD.
Creek
UNT to Millard
WW-T12-21007A 55.1 5.04 Ephemeral Minor No CWF, MF Wild Trout Waters Jan. 1–Sept. 30 Dam-and-pump Stream type is not HQ. This stream was not further analyzed for HDD.
Creek
UNT to Tower
WW-T92-21002 M-0061 0.1 3.63 Ephemeral Minor No CWF, MF Wild Trout Waters Jan. 1–Sept. 30 Dam-and-pump Stream type is not HQ. This stream was not further analyzed for HDD.
Branch
UNT to Tower
WW-T12-21009A M-0061 0.1 15 Perennial Minor No CWF, MF Wild Trout Waters Jan. 1–Sept. 30 Dam-and-pump Stream type is not HQ. This stream was not further analyzed for HDD.
Branch
WW-T48-21001 Tower Branch 56.8 17.96 Perennial Intermediate No CWF, MF Wild Trout Waters Jan. 1–Sept. 30 Dam-and-pump Stream type is not HQ. This stream was not further analyzed for HDD.
UNT to Tower
WW-T17-21001 57.2 7.38 Ephemeral Minor No CWF, MF Wild Trout Waters Jan. 1–Sept. 30 Dam-and-pump Stream type is not HQ. This stream was not further analyzed for HDD.
Branch

Table 4: Wetlands Assessed for HDD
Wetland ID Milepost Crossing Length (feet) Cowardin Class EV? (Yes/No) PFO Impacts (acres) SUMMARY
W-T30-21002 51.5 49.0 PEM No 0 Wetland is not Exceptional Value, and was not considered further for HDD.
W-T50-21002 54.1 7.6 PFO Yes <0.1 Wetland is Exceptional Value, however PFO impacts were less than 1 acre. This wetland was not further considered for HDD.
W-T50-21003 54.1 8.5 PFO Yes <0.1 Wetland is Exceptional Value, however PFO impacts were less than 1 acre. This wetland was not further considered for HDD.
W-T12-21008 55.1 33.5 PEM Yes 0 Wetland is Exceptional Value, however PFO impacts were less than 1 acre. This wetland was not further considered for HDD.
W-T12-21009 55.4 435 PEM/ PSS/ PFO Yes 0.3 Wetland is Exceptional Value, however PFO impacts were less than 1 acre. This wetland was not further considered for HDD.
W-T48-21002 M-0062 0.2 272.5 PEM/PFO No 0.1 Wetland is not Exceptional Value, and was not considered further for HDD.

Appendix A
Flow Chart of Trenchless Crossing Analysis
ATLANTIC SUNRISE PROJECT Trenchless Crossing Analysis

Conventional Bore Assessment
Perform Dry Open Cut
Phase 1: Stream
Designation
Intermittent &
Perennial Streams HDD Assessment
Phase 1: Feature Classification

Intermittent & Perennial
Designated Yes streams not being bored.
Intermittent (See bore assessment) Wetlands
Stream? Minimal resource impacts
using dry open cut
No Minimal resource impacts using
dry open cut No Designated Designated
Designated as HQ or EV? as HQ or EV?
Perennial No
Stream? Yes
Minimal resource impacts using Yes
dry open cut
Yes
Phase 2: Feature
Phase 2: Minimal resource impacts using Characteristics
Topography dry open cut Yes Designated
Equipment limitations exceeded
Assessment Intermittent
Is the bore No for conventional bore
length Stream?
<300’? No
No PFO with
impacts > 1
Yes Excessive workspace, impacts, cost for Minimal resource impacts acre
conventional bore using dry open cut Perennial
Yes Yes
Are bore pits No streams < 30’
<20’ in (TOB-TOB)
depth?
Yes No
Develop Workspace Develop Workspace
Phase 3: Desktop Phase 3: Desktop

Assessments Assessments
Phase 3A: Impacts Assessment Phase 3B: Risk Assessment Phase 2A: Impacts Assessment Phase 2B: Risk Assessment
1) PFO, PEM, PSS Wetlands; 1) PFO, PEM, PSS Wetlands;
Uplands; Land Use; 1) Construction risks related to
Uplands; Land Use; Other 1) Construction risks related to HDDs
Other conventional bores.
2) HQ / EV 2) Does the bore cross an area with

2) HQ / EV 2) Are the bore pits located in shallow
medium to high karst potential?
bedrock that may require blasting?
3) Water Consumption
3) Noise 3) Other
3) Does the bore cross an area with
medium to high karst potential? 4) Noise
4) Construction Duration
4) Other 5) Air Emissions
6) Construction Duration
Significant resource impacts, construction Significant resource impacts,

Using Phase 3 risk using conventional bore construction risk using an HDD Using Phase 2
Assessments, No No Assessments,
is a bore is an HDD
practical? practical?
Yes Yes
Phase 4: Soil Borings Phase 4: Soil Borings

Phase 4: Perform soil borings to confirm Phase 3: Perform soil borings to confirm
subsurface conditions. Review findings. subsurface conditions. Review findings.
Significant construction risk due to Significant construction risk due to

subsurface conditions, equipment subsurface conditions, equipment
Based on verified limitations for a conventional bore limitations for an HDD Based on verified
subsurface No No subsurface
conditions, is a bore conditions, is an
still feasible? HDD still feasible?
Yes Yes
Pool of practical, constructible Pool of practical, constructible

conventional bores identified. HDD crossings identified.
Pool of trenchless crossings identified through

CB and HDD assessments
Equipment / Skilled Asses equipment and skilled labor

Labor Assessment availability.
Identify the most critical trenchless No Are all proposed Yes

crossings that the project is trenchless crossings
capable of supporting. still feasible?
Dry open cut those Execute conventional

Execute bores and HDDs as
crossings that the
conventional bores identified through
project is unable to
and HDDs that the
support with trenchless conventional bore and
project can support. HDD assessments.
construction.

P6 - Att P SUSQ - APP P-2 - SUSQ - Trench - v1

Uploaded by

Document Information

Original Title

Copyright

Available Formats

Share this document

Share or Embed Document

Sharing Options

Did you find this document useful?

Is this content inappropriate?

Copyright:

Available Formats

P6 - Att P SUSQ - APP P-2 - SUSQ - Trench - v1

Uploaded by

Copyright:

Available Formats

TRENCHLESS CROSSING ANALYSIS

Transcontinental Gas Pipe Line Company, LLC

ATLANTIC SUNRISE PROJECT

Central Penn Line

1.0 INTRODUCTION ......................................................................................................................................... 1

ATLANTIC SUNRISE PROJECT ii Trenchless Crossing Analysis

Figure 1: Bore Pit Depth - Determining Factors ......................................................................................... 22

Appendix A Flow Chart of Trenchless Crossing Analysis

ATLANTIC SUNRISE PROJECT iii Trenchless Crossing Analysis

 25 PA. Code §§ 105.13(e)(1)(viii) – Alternatives analysis. A detailed analysis of alternatives to

ATLANTIC SUNRISE PROJECT 1 Trenchless Crossing Analysis

1.1 Project Background

ATLANTIC SUNRISE PROJECT 2 Trenchless Crossing Analysis

1.2 Project Design and Construction Practices Employed

 Lies within an existing ROW or easement; or

ATLANTIC SUNRISE PROJECT 3 Trenchless Crossing Analysis

2.0 TYPICAL CONSTRUCTION METHODS

2.1.1 Dam-and-Pump Crossing

ATLANTIC SUNRISE PROJECT 4 Trenchless Crossing Analysis

2.1.2 Flume Crossing

2.1.3 Wet Open-Cut Crossing Method

ATLANTIC SUNRISE PROJECT 5 Trenchless Crossing Analysis

2.1.4 Duration of Construction

2.2 Wetland Crossing Procedures

 Standard Pipeline Construction (non-saturated wetland),

ATLANTIC SUNRISE PROJECT 6 Trenchless Crossing Analysis

2.2.2 Conventional Wetland Construction (Saturated)

2.2.3 Push-Pull Technique

ATLANTIC SUNRISE PROJECT 7 Trenchless Crossing Analysis

3.0 TRENCHLESS CONSTRUCTION – CONVENTIONAL BORE

3.2 Conventional Bore Risk Factors

3.2.1 Site Constraints and Topographic Considerations

ATLANTIC SUNRISE PROJECT 8 Trenchless Crossing Analysis

3.2.2 Mixed-Face Condition

3.2.4 Soil Conditions

ATLANTIC SUNRISE PROJECT 9 Trenchless Crossing Analysis

ATLANTIC SUNRISE PROJECT 10 Trenchless Crossing Analysis

3.2.6 Drill Hole Failure

4.0 TRENCHLESS CONSTRUCTION – HORIZONTAL DIRECTIONAL

Risks associated with a HDD crossing technique include:

ATLANTIC SUNRISE PROJECT 11 Trenchless Crossing Analysis

4.2 HDD Risk Factors

4.2.1 Site Constraints and Topographic Considerations

ATLANTIC SUNRISE PROJECT 12 Trenchless Crossing Analysis

ATLANTIC SUNRISE PROJECT 13 Trenchless Crossing Analysis

4.2.2 Elevation Differential and Dry Hole

4.2.3 Hole Stability

Soil Portions of the HDD Profile

Rock Portions of the HDD Profile

ATLANTIC SUNRISE PROJECT 14 Trenchless Crossing Analysis

4.2.5 Pilot Hole Steering

ATLANTIC SUNRISE PROJECT 15 Trenchless Crossing Analysis

4.2.6 Drilling Fluid Loss, Hydraulic Fracture and Inadvertent Returns

4.2.7 Poor Cuttings Removal

ATLANTIC SUNRISE PROJECT 16 Trenchless Crossing Analysis

4.2.9 Downhole Tooling Failure / Loss

4.2.10 HDD Time of Installation

4.3 HDD Environmental Factors

ATLANTIC SUNRISE PROJECT 17 Trenchless Crossing Analysis

ATLANTIC SUNRISE PROJECT 18 Trenchless Crossing Analysis

Table 1: Summary of Construction Methods for the Atlantic Sunrise Project

90 feet wide x length of

Geotechnical investigations requiring access road